Privacy Policy
Last Updated:
HeartScene is privacy-first by design.
Your conversations are encrypted in transit and at rest and are not routinely read; they are reviewed only when flagged for safety or when you ask support for help. Your photos are stored in Canada. Your voice is transcribed in real time — not stored. We never sell your data or use it to train AI.
🔒 Privacy at a Glance
- Your conversations are encrypted in transit and at rest; they are not routinely read, and are reviewed only when flagged for safety or when you ask support for help
- We never sell your personal data to third parties — ever
- Your voice is transcribed in real time and immediately discarded — no voice recordings are stored
- Your photos are stored only in Canada (ca-central-1, Montreal) — never used to train AI
- AI processes your messages to generate responses — Anthropic is contractually prohibited from training on them (see Section 7)
- You can delete your data at any time from your account settings
- GDPR, CCPA/CPRA compliant — exercise your rights anytime
- PIPEDA & Quebec Law 25 compliant — Canadian privacy law honoured
1. Introduction
Welcome to HeartScene ("we," "us," "our," or the "Company"). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you access or use our website, mobile application, and related services (collectively, the "Service").
By using HeartScene, you consent to the data practices described in this Privacy Policy. If you do not agree with our policies and practices, please do not use our Service.
This Privacy Policy is compliant with:
- General Data Protection Regulation (GDPR) — European Union
- California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) — California, USA
- Personal Information Protection and Electronic Documents Act (PIPEDA) — Canada (Federal)
- Quebec Law 25 (An Act to modernize legislative provisions as regards the protection of personal information) — Quebec, Canada
- Canada's Anti-Spam Legislation (CASL) — for commercial electronic messages
- Other applicable data protection laws
2. Definitions
For the purposes of this Privacy Policy:
- "Personal Data" means any information relating to an identified or identifiable natural person.
- "Processing" means any operation performed on Personal Data, whether automated or not.
- "Data Subject" means the individual to whom Personal Data relates (you, the user).
- "Service Provider" means any third party that processes data on our behalf.
- "AI Companion" means the artificial intelligence-powered chat entities within HeartScene.
- "Cookies" means small data files stored on your device.
3. Data Controller Information
Data Controller:
Melaku Digital Inc.
Ontario, Canada
Email: support@heartscene.app
Website: heartscene.app
As the Data Controller, we determine the purposes and means of processing your Personal Data and are responsible for ensuring compliance with applicable data protection laws.
4. Information We Collect
4.1 Information You Provide Directly
- Account Information: Email address, display name, profile picture (optional)
- Age Admission: Full date of birth and timestamped acceptance of the Terms and Privacy Policy, stored to check eligibility for this 18+ app. Date-of-birth collection for admission is separate from optional birthday celebrations.
- Chat Content: Messages you send to AI companions (including Study Buddy, Social Skills Trainer, Conversation Coach and Supportive Listener personas), custom companion configurations
- Payment Information: Billing address, payment method details (processed by Stripe — we do not store full card numbers)
- Support Communications: Messages sent to customer support
- User Preferences: Theme settings, notification preferences, companion preferences
4.2 Information Collected Automatically
- Device Information: Device type, operating system, browser type, screen resolution
- Usage Data: Pages visited, features used, time spent, click patterns
- Log Data: IP address, access times, referring URLs, error logs
- Location Data: Approximate location based on IP address (country/region level only)
4.3 Information from Third Parties
- OAuth Providers: If you sign in via Google, we receive your email, name, and profile picture. Google authenticates you under Google's Privacy Policy (policies.google.com/privacy); the sign-in itself is handled by Supabase Auth, our authentication provider.
- Payment Processors: Transaction confirmations and payment status from Stripe
- Analytics Services: Aggregated usage statistics
5. Legal Basis for Processing (GDPR)
We process your Personal Data under the following legal bases:
| Purpose | Legal Basis |
|---|---|
| Providing the Service | Contract Performance (Art. 6(1)(b)) |
| Processing payments | Contract Performance (Art. 6(1)(b)) |
| AI processing of messages | Consent (Art. 6(1)(a)) |
| Analytics and improvement | Legitimate Interest (Art. 6(1)(f)) |
| Marketing communications | Consent (Art. 6(1)(a)) |
| Legal compliance | Legal Obligation (Art. 6(1)(c)) |
| Fraud prevention | Legitimate Interest (Art. 6(1)(f)) |
6. How We Use Your Information
We use your Personal Data for the following purposes:
6.1 Service Delivery
- Creating and managing your account
- Providing AI companion chat functionality
- Processing transactions and managing subscriptions
- Syncing data across your devices
6.2 Service Improvement
- Analyzing usage patterns to improve features
- Developing new features based on user feedback
- We do not use your conversation content to train AI models. See Section 7.2 for full AI training disclosure.
- Fixing bugs and technical issues
6.3 Communication
- Sending transactional emails (receipts, account updates)
- Providing customer support
- Sending marketing communications (with consent)
- Notifying you of policy changes
6.4 Safety and Security
- Preventing fraud and abuse
- Enforcing our Terms of Service
- Protecting user safety
- Complying with legal requirements
6.5 Mental Health & Eating Disorder Safety Detection
🛡️ Automated Safety Detection
HeartScene's AI systems automatically scan conversation content for language that may indicate:
- Suicidal ideation or self-harm urges
- Eating disorder behaviors (restriction, purging, body image distress)
- Crisis-level emotional distress
When such language is detected, the AI companion breaks from its character role and provides compassionate, non-judgmental support alongside professional helpline information (National Alliance for Eating Disorders, NEDIC, Beat, 988 Lifeline).
How the detection runs. The first pass is pattern matching that runs on our own servers. Where a message is ambiguous, we may also ask our AI provider (Anthropic) for a second opinion, which means the message text is sent to them for that check — the same provider that already receives your message in order to generate the companion's reply. We do not use a separate third-party screening service.
What we keep. When a safety response is triggered we record the event — the signals matched, the severity, a timestamp and a short excerpt of the message — so our safety administrator can review it. Detection records are not used for advertising, profiling, or AI training.
7. AI Processing Disclosure
⚠️ Important AI Disclosure
HeartScene uses artificial intelligence to generate chat responses. This section explains how your data is processed by AI systems.
7.1 How AI Processing Works
- Your messages are sent to AI language models (currently Claude by Anthropic) to generate responses
- AI companions are not real people — they are software programs
- Responses are generated in real-time based on your input and companion personality
- We may store conversation history to provide context for future conversations
- Photos you share may be analysed by our AI provider solely to generate your companion's reaction; they are not used to train AI models
7.2 AI Training Data
Your conversation data is processed by Anthropic solely to generate your AI companion responses. Anthropic's API terms prohibit use of API inputs/outputs for model training by default. HeartScene does not separately use your conversations to train AI models. The AI improvement opt-out in your account settings controls whether anonymized usage patterns (not conversation content) may be used to improve HeartScene's companion configurations.
7.3 Duty of Loyalty Commitment
HeartScene's AI companions operate under a Duty of Loyalty as defined in our Terms of Service §6.6. This means our AI will never manufacture emotional urgency to drive purchases, will never agree with self-destructive plans or harmful beliefs, and will always redirect users in crisis to professional resources. This commitment is built into every AI companion system prompt and is not optional or configurable.
7.4 Communication Coach & Voice
The Communication & Confidence Coach lets you record spoken answers to get coaching feedback. We handle that audio with privacy by design:
- Your recording is transcribed, then immediately discarded. We send the audio to our transcription sub-processor, OpenAI (Whisper), to convert speech to text. Under our agreements, your audio is not used to train AI models. We never store your voice — there is no voiceprint or audio recording kept on our systems.
- We keep only the transcript and your coaching scores (and, for the optional Communication Clone, a profile of scores and text-derived insights) so we can show your progress over time.
- Consent. Before your first recording we ask for your explicit consent, with an additional notice before the longer 10–20 minute Communication Clone recording. Consent is recorded with a timestamp and version.
- Retention. We keep your coaching transcripts while your account is active. If your account is dormant for more than 18 months, we purge the transcript text (keeping only the numeric scores). Deleting your account removes all of it.
- Your controls. In the Coach you can delete any individual session or all of your coaching history at any time, and delete your Communication Clone.
Melaku Digital Inc. is the data controller for this processing under PIPEDA, the GDPR, and the CCPA/CPRA. Voice is treated as sensitive personal information; we minimize it by never retaining the audio itself.
9. International Data Transfers
HeartScene's primary user data is stored on servers located in Montreal, Quebec, Canada. However, some third-party service providers (such as Anthropic, Stripe, and OpenAI) used by HeartScene are located in the United States or other jurisdictions. By using the Service, you understand that some portion of your data (such as your chat messages or payment details) may be transferred to and processed in the United States, where it may be subject to lawful access requests by U.S. authorities under applicable laws.
Under the General Data Protection Regulation (GDPR), Canada has been recognized by the European Commission as providing an "adequate" level of data protection (pursuant to PIPEDA). This means personal data from the EU/EEA can flow to our Canadian servers without requiring additional safeguards like Standard Contractual Clauses (SCCs) for primary storage. For any subsequent transfers to U.S.-based sub-processors, HeartScene relies on Data Processing Agreements (DPAs) incorporating standard contractual clauses where the U.S. provider is not certified under the EU-U.S. Data Privacy Framework.
10. Data Security Measures
We implement industry-standard security measures to protect your data:
- Encryption in Transit: All data transmitted using TLS 1.3 encryption
- Encryption at Rest: Database encrypted using AES-256
- Access Controls: Role-based access with multi-factor authentication for staff
- Row-Level Security: Database policies ensure users can only access their own data
- Regular Audits: Periodic security assessments and vulnerability testing
- Secure Development: Security reviews in our development process
While we strive to protect your data, no method of transmission or storage is 100% secure. If you believe your account has been compromised, please contact us immediately.
11. Data Retention
⏱️ Automatic Retention Policy
HeartScene retains your personal data for as long as your account is active. If your account has been inactive for 23 months, we will send you an email informing you that your account is scheduled for deletion in 30 days. To keep your account, simply log in within that 30-day period.
After 2 years of inactivity with no response to our notification, your account and all associated personal data will be permanently deleted from all systems. This policy applies automatically to all accounts and satisfies the requirements of Quebec Law 25 (s.23) and PIPEDA Principle 5.
You may request immediate deletion of your account and data at any time through your account settings or by emailing support@heartscene.app.
Retention periods by data category:
| Data Type | Retention Period | Legal Basis |
|---|---|---|
| Conversation history | Until account deletion or 2-year inactivity deletion | PIPEDA Principle 5 |
| AI companion memory | Until account deletion or 2-year inactivity deletion | GDPR Art. 5(1)(e) |
| Payment records | 7 years | Canadian tax law — CRA requirement |
| Security & moderation logs | 90 days | Operational security |
| Age verification records | Duration of account + 1 year | Minor protection compliance |
| Consent records | Duration of account + 3 years | PIPEDA audit requirement |
| Data retention audit log | Permanent (admin-only) | Quebec Law 25 accountability |
12. Your Rights Under GDPR (European Users)
If you are in the European Economic Area (EEA), UK, or Switzerland, you have the following rights:
- Right to Access (Art. 15): Request a copy of your Personal Data
- Right to Rectification (Art. 16): Correct inaccurate or incomplete data
- Right to Erasure (Art. 17): Request deletion of your data ("right to be forgotten")
- Right to Restrict Processing (Art. 18): Limit how we use your data
- Right to Data Portability (Art. 20): Receive your data in a machine-readable format
- Right to Object (Art. 21): Object to processing based on legitimate interests
- Right to Withdraw Consent (Art. 7): Withdraw consent at any time
- Right to Lodge a Complaint: File a complaint with your local data protection authority
To exercise your rights, contact us at support@heartscene.app. We will respond within 30 days.
13. Your Rights Under CCPA/CPRA (California Residents)
If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):
13.1 Your Rights
- Right to Know: Request disclosure of Personal Information collected, used, and shared
- Right to Delete: Request deletion of your Personal Information
- Right to Correct: Request correction of inaccurate Personal Information
- Right to Opt-Out: Opt out of the sale or sharing of Personal Information
- Right to Limit Use: Limit use of sensitive Personal Information
- Right to Non-Discrimination: Not be discriminated against for exercising your rights
13.2 Categories of Personal Information
In the past 12 months, we have collected the following categories of Personal Information:
- Identifiers (email address, account name, IP address)
- Commercial information (purchase history, subscription status)
- Internet activity (browsing history, interactions with the Service)
- Inferences (preferences, characteristics derived from usage)
13.3 "Do Not Sell or Share My Personal Information"
We do not sell your Personal Information. We do not share your Personal Information for cross-context behavioral advertising. If this changes, we will update this policy and provide an opt-out mechanism.
13.4 How to Submit Requests
To exercise your CCPA/CPRA rights:
- Email: support@heartscene.app
- Use account settings to delete your data
We will verify your identity before fulfilling requests. You may designate an authorized agent to submit requests on your behalf.
14. Your Rights Under Canadian Law (PIPEDA & Quebec Law 25)
HeartScene is operated from Canada and is subject to the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and, for Quebec residents, Quebec's Law 25 (An Act to modernize legislative provisions as regards the protection of personal information).
14.1 Your Rights Under PIPEDA
- Right of Access: Request a copy of all personal information we hold about you
- Right to Correct: Request correction of inaccurate or incomplete personal information
- Right to Withdraw Consent: Withdraw consent to collection or use of your personal information at any time, subject to legal or contractual restrictions
- Right to Challenge: Challenge our compliance with PIPEDA to our Privacy Officer
- Right to Complain: File a complaint with the Office of the Privacy Commissioner of Canada (OPC) at priv.gc.ca
14.2 Additional Rights Under Quebec Law 25
Quebec residents have enhanced rights under Law 25, which came fully into force September 22, 2023:
- Right to Erasure ("Right to be Forgotten"): Request deletion of personal information when it is no longer necessary for its original purpose
- Right to Data Portability: Receive your personal information in a structured, commonly used technological format
- Right to Object to Automated Decision-Making: Be informed when automated processing is used to make decisions about you and request human review
- Right to De-indexing: Request removal of hyperlinks that provide access to your personal information when continued dissemination causes you harm
- Right to Lodge a Complaint: File a complaint with the Commission d'accès à l'information (CAI) at cai.gouv.qc.ca
14.3 Our PIPEDA Consent Practices
HeartScene obtains meaningful, informed, and granular consent. At sign-up we collect your age confirmation and your agreement to these policies; the per-category consents below are presented and controlled in Settings → Privacy, where you can review or withdraw each one:
- We present each data collection category separately with plain-language explanations
- We identify required vs. optional consent clearly
- We explain exactly what data is stored, how long, and why
- We maintain an audit trail of all consent decisions as required by PIPEDA Principle 4.3
- You may withdraw optional consents at any time from Settings → Privacy
14.4 AI Memory & Personal Data Disclosure
HeartScene's AI companions use a memory system that stores personal information you share in conversations — such as your name, birthday, preferences, goals, and life events. This is disclosed clearly at the point of collection, and storage requires your explicit consent.
- You can view all stored memories at any time via the Memories page
- You can edit or delete individual memory items
- Withdrawing AI Memory consent stops new memories from being stored
- Existing memories can be bulk-deleted via Settings → Privacy → Delete My Data
16. Children's Privacy
🔞 Age Restriction
HeartScene is intended for users who are at least 18 years old. We do not knowingly collect Personal Data from anyone under 18.
If we learn that we have collected Personal Data from a child under 18, we will take steps to delete that information as quickly as possible. If you believe a child under 18 has provided us with Personal Data, please contact us at support@heartscene.app.
🔐 Payment Method Age Verification
When paid plans are open, HeartScene uses payment method information as one layer of its age checks. Paid plans are closed during our beta, so none of the processing below is happening today.
- Card payments: When you pay by credit or debit card, we compare the cardholder name returned by Stripe to your HeartScene account name. This is a name-matching check only. We do not store the cardholder name separately from your account data.
- Name mismatch: Where names do not match, we use Stripe Identity to verify your government-issued identification. Stripe Identity processes and retains identity documents under their own privacy policy (stripe.com/privacy). HeartScene does not store your ID documents.
- Payment methods other than a card: If you pay with a method other than a card (PayPal is not accepted today), the payment first requires a Stripe Identity check: a government photo ID plus a matching selfie, processed by Stripe under its own privacy policy, because these methods do not provide a verifiable identity signal on their own. HeartScene receives only a pass/fail result and the method label (
stripe_identity). HeartScene does not store your date of birth, ID number or images. Each account gets at most two attempts in any 30 days. - Cryptocurrency: We do not accept cryptocurrency payments. Cryptocurrency transactions carry no identity information, making it impossible to verify that the payer is an adult. Operating an 18+ platform requires that every accepted payment method provides a verifiable identity signal.
🔐 Enhanced Age Verification — not currently available
Today, age is established by the date of birth you declare at signup, which our servers validate and enforce. We have built an optional enhanced check with Yoti as an alternative to self-declaration, but it is not enabled in the product. The paragraphs below describe what would and would not be shared with us if we turn it on; we will update this policy before relying on it.
- What Yoti collects: Yoti may process identity documents or biometric data on their own platform to estimate or verify your age. HeartScene does not receive or store any identity document, facial image, or biometric data.
- What HeartScene receives: A pass/fail age confirmation result and the verification method label (
yoti_avs) only. - What HeartScene records: The verification result (pass/fail), the method used, and a hashed IP address for fraud prevention. No government ID information is stored by HeartScene at any time.
- Yoti's privacy policy: yoti.com/privacy-policy
Enhanced verification would be entirely voluntary. The standard date-of-birth method is what applies today.
17. Do Not Track Signals
Some browsers have a "Do Not Track" (DNT) feature that sends a signal to websites requesting that your browsing behavior not be tracked. Currently, there is no uniform standard for interpreting DNT signals. Our Service does not currently respond to DNT signals, but we provide other privacy controls as described in this policy.
18. Specialized AI Companion Disclaimers
HeartScene offers specialized AI companions designed to support various aspects of personal development. It is important to understand the scope and limitations of these AI services:
📚 Study Buddy AI
Study Buddy companions are not certified tutors, teachers, or educational professionals. They are AI-powered tools designed to provide motivation, general learning support, and study organization assistance. They do not replace qualified educators or professional academic tutoring services.
💬 Social Skills Trainer AI
Social Skills Trainer and Conversation Coach companions are designed for conversation practice and confidence building in a private, judgment-free environment. They are not licensed counsellors or mental health professionals, and HeartScene never introduces or connects you with other real people. They should not be used as a substitute for professional advice or care.
🫂 Supportive Listener AI
Supportive Listener companions are fictional characters that listen without judgement. They are not licensed professionals of any kind, and not a support or crisis service. They cannot diagnose, treat, or advise on any health matter and will decline if asked. If you are in crisis or dealing with a serious health condition, please contact a qualified provider or your local emergency number immediately.
⚠️ Important: When to Seek Professional Help
HeartScene AI companions are supplementary tools and do not replace professional services. Please seek qualified professional help if you:
- Are experiencing suicidal thoughts or self-harm urges (Call or text 988 — Canada & US, 24/7)
- Are struggling with an eating disorder (USA: National Alliance for Eating Disorders helpline — allianceforeatingdisorders.com | Canada: NEDIC 1-866-633-4220 | UK: Beat 0808 801 0677)
- Have severe depression, anxiety, PTSD, or other mental health conditions
- Need academic tutoring for critical exams or coursework
- Require professional relationship or couples counseling
- Are dealing with trauma, abuse, or addiction
- Have any medical or psychological condition requiring professional treatment
By using HeartScene's specialized AI companions, you acknowledge and agree that they are entertainment and self-improvement tools only, not substitutes for professional services. HeartScene and its operators assume no liability for outcomes resulting from reliance on AI companion advice or guidance.
19. Local Device Cache
To reduce loading times, HeartScene stores a temporary copy of recent chat messages in your browser's IndexedDB storage (a standard browser database on your device).
What this means for you
- Purpose: Performance only — reduces round-trips to our servers so messages appear faster.
- What is stored: Message content, role (user/assistant), companion ID, and timestamp — for up to 200 messages per companion.
- Where it is stored: On your device only, within your browser's IndexedDB. It is not transmitted to any third party.
- Access: The cache is accessible to other scripts running on the same origin (heartscene.app). It is not encrypted.
- Retention: The cache is automatically cleared when you log out or delete your account. You can also clear it manually at any time from Settings → Privacy.
- Authority: Supabase (our server database) is the sole authoritative record of your messages. The local cache is ephemeral and can be cleared without any data loss.
To clear your local cache immediately, visit Settings → Privacy and click "Clear cached data from this device."
20. Policy Updates
We may update this Privacy Policy from time to time. When we make material changes, we will:
- Update the "Last Updated" date at the top of this policy
- Notify you via email or in-app notification (for significant changes)
- Provide a summary of changes
Your continued use of the Service after changes become effective constitutes acceptance of the revised Privacy Policy. We encourage you to review this policy periodically.
21. Contact Information
For questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
Privacy Officer & Data Protection Officer
HeartScene's designated Privacy Officer (under PIPEDA) and Data Protection Officer (under GDPR) is: Etefworkie Melaku, Melaku Digital Inc.
Both roles are fulfilled by the same individual.
Email: support@heartscene.app
General Support
Email: support@heartscene.app
We respond to all privacy requests within 30 days as required by PIPEDA and GDPR Article 12. If you are unsatisfied with our response, you may escalate to the Office of the Privacy Commissioner of Canada (priv.gc.ca) or your local EU/EEA supervisory authority.
This Privacy Policy was drafted in accordance with the requirements of the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), and other applicable data protection laws. This document should be reviewed by a qualified legal professional before final implementation.